Beta Version

Website Last updated:

June 26, 2026

This treaty addresses double taxation on income and capital between Kuwait and Cyprus, covering Cyprus's income, special contribution, and capital gains taxes, and Kuwait's corporate tax. A permanent establishment is created by a building site lasting over 12 months. The dividend withholding rate is 10%, though dividends from a Cyprus company to a Kuwait resident are exempt from additional Cyprus tax. The interest rate is 10%. The royalty rate is 5% for industrial or scientific use, while copyright royalties are exempt from source-state tax. The credit method eliminates double taxation.

Agreement between the Government of the Republic of CYPRUS and the Government of the State of KUWAIT for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital

AGREEMENT OF 15^th DECEMBER, 1984

This is a Convention between the Republic of Cyprus and the Government of the State of Kuwait for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital.

The Government of the Republic of Cyprus and the Government of the State of Kuwait desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, have agreed as follows:

Contents

Article 1 - Personal Scope

Article 2 - Tax Covered

Article 3 - General Definitions

Article 4 - Fiscal Domicile

Article 5 - Permanent Establishment and Permanent Base

Article 6 - Income from Immovable Property

Article 7 - Business Profits

Article 8 - Shipping & Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Dependent Personal Services

Article 16 - Directors Fees

Article 17 - Artistes and Athletes

Article 18 - Governmental Functions

Article 19 - Pensions

Article 20 - Students

Article 21 - Income Not Expressly Mentioned

Article 22 - Capital

Article 23 - Methods for the Elimination of Double Taxation

Article 24 - Limitation of Relief

Article 25 - Non-Discrimination

Article 26 - Mutual Agreement Procedure

Article 27 - Exchange of Information

Article 28 - Diplomatic Agents and Consular Officers

Article 29 - Entry into Force

Article 30 - Termination and Amendment

Article 1
Personal Scope

This Convention shall apply to persons who are residents of one or both of the Contracting States.

Article 1Personal Scope

Article 2Tax Covered

Article 1
Personal Scope

Article 2
Tax Covered